purview-customer-key

name	purview-customer-key
description	Guidance for Microsoft Purview Customer Key and Double Key Encryption (DKE) — customer-controlled encryption for service-side data (Customer Key for Exchange/SharePoint/OneDrive/Teams/Purview) and client-side double encryption for highly sensitive documents (DKE via sensitivity labels and a customer-hosted key service). Covers Azure Key Vault setup (HSM-backed, recoverable, soft-delete, purge protection, redundant regions), data encryption policies (DEPs) for M365 services, key rotation and revocation, DKE service deployment (containerized key release service), DKE label authoring, end-user experience trade-offs (no eDiscovery into DKE content), and decision criteria vs Microsoft-managed encryption. WHEN: Customer Key M365, BYOK Exchange, DKE Microsoft, double key encryption, customer-managed keys SharePoint OneDrive Teams, key rotation Customer Key, HYOK alternative, sovereignty encryption, regulator-controlled encryption, sensitivity label DKE. DO NOT USE for Azure resource CMK (use azure-key-vault), general sensitivity labels (use purview-information-governance), or non-encryption compliance (use compliance-manager).
license	MIT
metadata	{"author":"Microsoft","version":"0.1.0"}

Microsoft Purview Customer Key & Double Key Encryption

Microsoft already encrypts M365 data at rest with Microsoft-managed keys. These additional controls let regulated or sovereignty-sensitive customers hold the keys themselves:

• Customer Key — customer-supplied root keys (in Azure Key Vault HSM) wrap service data-encryption keys for Exchange, SharePoint, OneDrive, Teams (chats/files), and Purview. Revoke the key → Microsoft can no longer decrypt → service-data path crypto- shredded.
• Double Key Encryption (DKE) — sensitivity-label-driven client-side encryption where one key is customer-held in a self-hosted key release service. Microsoft never sees that key; service-side features (search, eDiscovery, Copilot) cannot read the content.

This skill covers both — when to use which, the architectures, and the operational realities.

When to use

• Regulatory mandate to hold encryption keys (financial sector sovereignty, defense, certain EU public sector).
• Crypto-shredding requirement (provable destruction by key revocation).
• The highest-sensitivity documents that must not be readable by Microsoft or by any service-side process even temporarily.

Do not use this skill for Azure resource encryption (azure-key-vault), generic sensitivity-label rollout (purview-information-governance), or GRC frameworks (compliance-manager).

Customer Key vs DKE — pick consciously

Feature	Customer Key	DKE
Scope	All data in selected M365 services	Per-document, label-driven
Encryption point	Service-side, transparent	Client-side, before upload
Microsoft can read for service features?	Yes (until key revoked)	No
eDiscovery, Search, Copilot, DLP work on content?	Yes	No
Key custody	Azure Key Vault HSM (customer subscription)	Customer-hosted key release service (on-prem or your cloud)
Crypto-shred via revocation?	Yes (service-wide)	Per-document by destroying key
Use case	Sovereignty, blanket regulator demand	Crown-jewel docs only

Rule of thumb: Customer Key for tenant-wide sovereignty. DKE for the 0.1% of documents that must remain opaque even to internal cross-tenant features (board minutes, M&A drafts, weapon designs).

Approach

Customer Key

1. Provision Azure Key Vault in two separate Azure subscriptions/regions (paired). Mandatory settings:

   • HSM-backed key (RSA 2048+).
   • Soft-delete on, purge protection on (Customer Key onboarding will refuse otherwise).
   • Recovery level: Recoverable+ProtectedSubscription.
   • Diagnostic logs to a dedicated, long-retention Log Analytics workspace.

2. Create two root keys per service — one per region. M365 needs both available for wrap/unwrap. Losing one is recoverable; losing both is unrecoverable crypto-shredding.

3. Create Data Encryption Policies (DEPs) per service (Exchange/SharePoint/etc.), referencing the two root keys. Assign DEPs to tenant or per-mailbox/site (Exchange supports per-mailbox; SharePoint is tenant-wide for the geo).

4. Rotate keys annually (or per policy) by adding a new key version; Microsoft automatically re-wraps. Never delete the old version while it might be in use.

5. Revocation runbook (the whole point). Document exactly: who authorizes, what command, who is notified, what the customer-facing impact is. Practice the revocation in a non-prod tenant. A real revocation is the only path to crypto-shredding — ensure governance.

6. Monitor. Alert on any change to the Key Vault access policy, key permissions, or M365 service principal assignments.

Double Key Encryption

1. Decide the document population. DKE breaks search, DLP, Copilot, eDiscovery on those documents. Limit to a small, well-defined set.

2. Stand up the DKE service.

   • Containerized .NET service (Microsoft-published image).
   • Hosted in your environment (on-prem, AWS, GCP, or Azure outside the M365 tenant).
   • Reachable from end-user clients via HTTPS; client-cert or OAuth to your IdP for authorization.
   • HA: at least two regions/AZs. Outage = users can't open DKE-protected documents.

3. Generate and load keys. Each DKE label points at a key in the service. Plan for per-classification keys, not per-document keys (operational burden).

4. Author the DKE sensitivity label in Purview with DKE encryption option and the service endpoint URL.

5. Publish the label to the target user group (legal, M&A, board, etc.). Users see a new label option in Office; applying it triggers client-side encryption via the DKE service.

6. Communicate the trade-offs to users in writing. No search results, no Copilot summaries, no third-party scanning, no automatic transcription of DKE-labeled documents.

7. Backup the DKE keys with strict custody. Loss of DKE keys = permanent loss of all documents protected by that key.

Guardrails

• Customer Key + losing both root keys = data loss. Microsoft cannot recover. Treat the keys with the same custody you'd give an HSM root.
• Soft-delete + purge protection are mandatory and irreversible. Plan Key Vault governance up front.
• DKE breaks service-side features by design. Do not promise eDiscovery or Copilot on DKE content.
• DKE service is a hard availability dependency. Outage = document access outage. HA, monitoring, on-call.
• Customer Key does not encrypt the data on Microsoft's wire any differently — TLS remains the transport. Customer Key is a wrapping-key control, not a transport- encryption change.
• Crypto-shredding via Customer Key revocation affects the whole DEP scope. It's a blunt instrument; coordinate with Legal and customers if multi-tenant.
• Both controls are premium-licensed. Confirm SKUs and add-ons before scoping.
• HYOK (Hold Your Own Key, AD RMS-based) is the legacy ancestor of DKE; Microsoft's forward-looking guidance is DKE. Don't architect new HYOK.

Common anti-patterns

• "Customer Key with one Key Vault in one region" — single failure = service outage. Always two regions.
• "Revoked Customer Key in prod 'to test'" — caused a tenant-wide service-data outage; recovery requires Microsoft engagement. Practice in test tenant only.
• "DKE on every executive's mailbox" — eDiscovery requests fail across an entire population. Use sparingly.
• "DKE service in a single VM" — outage = users can't open the most sensitive docs.
• "Customer Key marketed internally as 'extra encryption'" — it's a key custody control, not stronger crypto. Communicate the actual value (revocation, sovereignty).
• "DKE keys backed up to an admin's OneDrive" — defeats the entire model.
• "Confused Customer Key with Customer Lockbox" — different products. Customer Lockbox = approval for Microsoft engineer access; Customer Key = key custody.

Example prompts

• Plan Customer Key rollout for Exchange Online and SharePoint across a multi-geo tenant — Key Vault topology and DEP design.
• Document the Customer Key revocation runbook with authorization steps and customer impact.
• Design DKE for board meeting minutes used by 12 directors — service architecture, HA, and user comms.
• Compare Customer Key vs DKE for a sovereignty requirement from a financial regulator.
• Key rotation plan for Customer Key with audit evidence for ISO 27001.
• Author the DKE label and pilot with 5 users in legal; identify broken workflows.
• Cost and operational impact estimate for adopting DKE on 1% of SharePoint content.

Microsoft Learn

• Customer Key overview: https://learn.microsoft.com/purview/customer-key-overview
• Customer Key setup: https://learn.microsoft.com/purview/customer-key-set-up
• Data encryption policies: https://learn.microsoft.com/purview/customer-key-manage
• Roll/rotate Customer Key: https://learn.microsoft.com/purview/customer-key-availability-key-roll
• Revoke Customer Key: https://learn.microsoft.com/purview/customer-key-overview
• DKE overview: https://learn.microsoft.com/purview/double-key-encryption
• DKE deploy service: https://learn.microsoft.com/purview/double-key-encryption-setup
• Customer Lockbox (distinct): https://learn.microsoft.com/purview/customer-lockbox-requests
• Service encryption (Microsoft-managed baseline): https://learn.microsoft.com/purview/office-365-service-encryption